OECD publicly published 33 comments received on draft examples prepared as part of the follow-up work on the interaction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds.
In the consultation draft, the OECD said that there is a need to continue to examine issues related to the treaty entitlement of non-CIV funds to ensure that the new treaty provisions that are being considered adequately address the treaty entitlement of non-CIV funds. The continued examination of these issues would also address two general concerns that governments have about granting treaty benefits with respect to non-CIV funds:
As part of the consultation, it was agreed that the following examples could be publicly released for comments with a view to determining whether or not they usefully clarify the application of the PPT rule to common transactions involving non-CIV funds:
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